“foreign tax credit”

International TaxSection 90 / Rule 128Section 90 / Rule 128571 judgments

The decision most relied on for foreign tax credit is Chandra Kishore Jha v. Mahavir Prasad (8 SCC 266), cited in 163 judgments on BharatTax.

Leading authorities on foreign tax credit

Chandra Kishore Jha v. Mahavir Prasad

8 SCC 266 · 1999 · Supreme Court

163

citing judgments

If a statute or law prescribes that a thing must be done in a particular manner, then it must be done in that manner alone and in no other way. This principle mandates strict adherence to statutory procedures.

Wipro Ltd. v. DCIT

382 ITR 179 · 2016 · High Court

122

citing judgments

Foreign Tax Credit (FTC) is allowable even if no tax is paid in India on the corresponding income due to deductions under sections 10A or 10AA, or losses in other units. The scope of income eligible for deduction under Section 10AA includes interest on deposits and realized gains on forward contracts.

Ms. Brinda Ramakrishna v. ITO

135 Taxmann.com 358 · 2022 · ITAT

109

citing judgments

The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.

CIT v. ACE Multitaxes Systems (P.) Ltd.

317 ITR 207 · 2009 · High Court

107

citing judgments

For claiming relief under Chapter VI-A deductions like Section 80IB or 80IA, the audit report in Form 10CCB is not mandatory to be filed with the return of income, but can be submitted before the assessment is completed.

Sambhaji and Others v. Gangabai and Others

17 SCC 117 · 2008 · Supreme Court

citing judgments

Procedural law serves as an aid to justice, not an obstruction, and should not ordinarily be construed as mandatory; it is subservient to substantive justice.

42 Hertz Software India (P.) Ltd. v. ACIT

139 Taxmann.com 448 · 2022 · ITAT

citing judgments

The claim for Foreign Tax Credit cannot be denied solely due to a delay in filing Form-67, as the requirement for filing Form-67 under Rule 128(9) is considered directory and not mandatory. The provisions of a Double Taxation Avoidance Agreement (DTAA) prevail over the Income-tax Act, 1961.

Duraiswamy Kumaraswamy v. PCIT

460 ITR 615 · 2024 · High Court

citing judgments

An assessee's claim for Foreign Tax Credit (FTC) cannot be rejected merely because Form 67 was filed after the due date under section 139(1), provided it is filed before the completion of assessment proceedings.

Sonakshi Sinha v. CIT

142 Taxmann.com 414 · 2022 · ITAT

citing judgments

The requirement to file Form 67 by the due date for claiming foreign tax credit is directory, not mandatory, if filed before the completion of assessment proceedings.

Judgments citing foreign tax credit

Asian Paints Limited, Santacruz vs. National Faceless Assessment Centre, Delhi

ITA 2696/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Jul 2024AY 2018-19

Section 143(3)Section 14ASection 2(43)Section 35Section 40Section 50Section 80GSection 90

against long term capital loss XIII 18 Non-Acceptance of Ground No. Ground No. additional claim of XIX XVI Foreign Tax Credit (FTC) 19 Disallowance of foreign Ground No. X tax credit claim u/s 90 and 91 of the Act Allowed by CIT(A) Department Appeal 2936/Mum/202 3063/Mum/202 3083/Mum/2023

Braino Brain Kids Academy P Ltd., Chennai vs. DCIT Corp Circle 1(1), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1447/CHNY/2024[2019-20]Status: DisposedITAT Chennai24 Jul 2024AY 2019-20

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1447/Chny/2024 िनधा"रण वष" / Assessment Year: 2019-2020 Braino Brain Kids Academy P Ltd., The Deputy Commissioner Of Temple Tower, 2Nd Floor, V. Income Tax, 672 Anna Salai, Cit Nagar, Corporate Circle -1(1), Nandanam, Chennai – 600 035. Chennai – 34. [Pan: Aaccb-6355-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. M. Karunakaran, Advocate ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/Date Of Hearing : 22.07.2024 घोषणा की तारीख/Date Of Pronouncement : 24.07.2024

For Appellant: Shri. M. Karunakaran, AdvocateFor Respondent: Shri. R. Clement Ramesh Kumar, CIT

Section 143(1)Section 90

only issue in this appeal of assessee is as regards to the order of the ld.CIT(A) confirming the disallowance on foreign tax credit of Rs.2,05,110/- for the delayed submission of Form No. 67. :-2-: ITA. No: 1447/Chny/2024 3. The brief facts are that, the assessee ... failed to file Form 67 within due date prescribed under rule 128(9) of I.T.Rules, 1962. Hence, the assessee is not eligible for foreign tax credit of Rs.2,05,119/- and dismissed the appeal of the assessee. Aggrieved by the order of the ld.CIT(A), assessee preferred an appeal before

Anand Bhairat, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeal filed by the assessee stands allowed for statistical purposes

ITA 1177/BANG/2024[2019-20]Status: DisposedITAT Bangalore24 Jul 2024AY 2019-20

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2019-20

For Appellant: Ms. Adam Kajabee, CAFor Respondent: Shri V. Parithivel, JCIT-DR

Section 139(1)Section 143(1)Section 154Section 90

Page 2 of 5 2. The Ld.AR submitted that the only issue that arises in the present appeal is regarding denial of foreign tax credit claimed by assessee u/s. 90 amounting to Rs.29,46,150/- in respect of taxes paid in USA. 3. The Ld.AR submitted that the assessee being

Cosmos Maya India Pvt Ltd, Mumbai vs. Central Processing Center, ITO-16(1)(3), Bengaluru

In the result, appeal of the assessee is allowed

ITA 2543/MUM/2024[2021-22]Status: DisposedITAT Mumbai24 Jul 2024AY 2021-22

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Prakash Jhunjhunwala, A/RsFor Respondent: Shri Akshay Tapadiya, Sr. D/R

Section 143(1)

substance of the grievance of the assessee is that the ld. CIT(A) erred in now allowing the foreign tax credit (FTC) in respect of the tax paid outside India for the reason that Form No. 67 had been filed after furnishing the return of income. 3. Briefly stated ... assessee could not file Form 67 along with the return of income and the return was processed disallowing the foreign tax credit of Rs.59,87,813/-. The assessee filed Form 67 on 17/11/2022 along with a rectification application. The claim of FTC was denied which order was affirmed

Kunal Ramesh Shah, Mumbai vs. ADIT CPC Bangaluru, Bangaluru

In the result, appeal of the assessee is allowed

ITA 2502/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Raj Kumar Chauhan, Hon’Ble

For Appellant: Shri Ravi Dasija, C.A. & Kiran Mehta, C.A., A/RsFor Respondent: Shri Sunil K. Agwane, Sr. D/R

Section 143(1)

substance of the grievance of the assessee is that the ld. CIT(A), erred in not holding that the assessee was entitled to Foreign Tax Credit (FTC) of Rs. 4,21,428/- merely on the ground that Form 67 was not filed along with the return of income. 3. Briefly ... with the return of income. 4. Representatives of both the sides heard at length. There is no dispute that the assessee holds a foreign tax credit certificate for Rs.4,21,428/-. In our considered opinion filing of Form 67 is procedural/directory requirement and is not mandatory requirement. Therefore, violation

Kasper Pieter Tideman, Pune vs. Income Tax Officer, Ward-7(1), Pune

In the result, the appeal of the assessee in ITA No

ITA 80/PUN/2024[2020-21]Status: DisposedITAT Pune23 Jul 2024AY 2020-21

Bench: Shri Inturi Rama Rao & Ms. Astha Chandra

For Appellant: Shri Pratik SandbhorFor Respondent: Shri Nitin Patil

Section 143(1)Section 154

under : “The appeal of the appellant against the Order u/s 154 for A.Y. 2020-21 on the very issue of allowability of foreign tax credit in case of belated filing of Form 67 was pending before the ld. CIT(A). It is brought to the attention ... favour of the appellant vide order dated 10/07/2024. Copy of the said order of CIT(A) is enclosed herewith. Therefore the disallowance of foreign tax credit to the appellant has been deleted and the appellant has been granted the foreign tax credit for A.Y. 2020-21 in the appeal against

Western Outdoor Interactive Pvt Ltd, Mumbai vs. Assessement Unit, Income Tax Department Asstt Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2474/MUM/2022[2018-19]Status: DisposedITAT Mumbai16 Jul 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR

Section 143(3)Section 234ASection 244ASection 270ASection 40

Adjustment towards provision of sales Ground No.4 (4.1 Ground No.2 and marketing supporting services. & 4.2) & 3 Non-grant of credit for foreign tax credit Ground No.4 Levy of interest under section 234A, 234B Ground No.5 & 234C Initiating penalty proceedings under Ground No.5 Ground No.6 section 270A

Western Outdoor Interactive Private Limited, Mumbai vs. Asstt. Comm. of Income Tax, Circle-16(1), Mumbai

ITA 2461/MUM/2022[2017-2018]Status: DisposedITAT Mumbai16 Jul 2024AY 2017-2018

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Dhanesh Bafna, Shri AmolFor Respondent: Shri Himanshu Sharma, CIT-DR

Section 143(3)Section 234ASection 244ASection 270ASection 40

Shruti Ahuja, Haryana, India vs. ITO Ward 2, Rohtak

The appeal of the assessee is dismissed in limine as infructuous

ITA 2007/DEL/2023[2021-22]Status: DisposedITAT Delhi10 Jul 2024AY 2021-22

Bench: Shri Kul Bharat & Shri Pradip Kumar Kedia

For Appellant: Shri Vishal Kalra, AdvocateFor Respondent: Shri Gurpreet Singh, Sr.DR

Section 139(1)Section 139(5)Section 143(1)Section 154Section 250Section 90

Tax Act, 1961 (the Act) concerning A.Y. 2020-21. 2. As per the grounds of appeal, the assessee has challenged the denial of Foreign Tax Credit (FTC) of Rs.5,94,987/- under Section 90 of the Act due to belated filing of Form No. 67 prescribed for 2 I.T.A. No.2007/Del/2023 ... Section 139(1) of the Act wherein the income received from assignments in Netherlands was omitted to be reported. Likewise, the claim of Foreign Tax Credit on such income was also not made. The assessee thereafter filed the revised return under Section 139(5) of the Act wherein the income

Ericsson India Global Services Pvt Ltd, New Delhi vs. ACIT Spl. Range 3, New Delhi

In the result, both the appeals of the assessee are allowed for statistical purpose

ITA 2368/DEL/2019[2014-15]Status: DisposedITAT Delhi10 Jul 2024AY 2014-15

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Vishal Kalra, Adv. &For Respondent: Sh. Vijay B. Vasanta, CIT-DR

Section 234BSection 90Section 92C

That on facts and in the circumstances of the case & in law, the Ld. CIT(A) erred in disallowing the claim of Foreign tax credit. ITA Nos. 2367 & 2368/Del/2019 2 Ericsson India Global Services Pvt. Ltd. 2.1 That on facts and in the circumstances of the case ... erred in law in disallowing the claim of Foreign tax credit without providing adequate opportunity of being heard to the assessee. 2.2 The Ld. CIT(A) has grossly erred on facts in stating that the assessee has not been able to demonstrate whether the corresponding income on which additional foreign

Anish Tandon, Delhi vs. ACIT Circle 70(1), Delhi

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2664/DEL/2023[2020-2021]Status: DisposedITAT Delhi04 Jul 2024AY 2020-2021

Bench: Shri Shamim Yahya & Shri Sudhir Pareekanish Tandon, Vs. Acit, Circle 70(1), M-205, Greater Kailash – Ii, Delhi. Delhi – 110 048. (Pan : Aadpt5486A) (Appellant) (Respondent) Assessee By : Shri Baldev Raj, Advocate Shri Maneesh Upneja, Advocate Revenue By : Shri Kanv Bali, Sr. Dr Date Of Hearing : 02.07.2024 Date Of Order : 04.07.2024 Order Per Shamim Yahya: This Appeal By The Assessee Is Directed Against The Order Of The Ld. Cit (Appeals)/National Faceless Appeal Centre (Nfac) Dated 28.07.2023 For The Assessment Year 2020-21. 2. Grounds Of Appeal Taken By The Assessee Read As Under :- “1. That The Order Under Section 250 Passed By The Learned Commissioner Of Income Tax (Appeals) Is Bad In Law, Wrong In Facts Against Natural Justice. 2. That The Learned Commissioner Of Income Tax (Appeals) Has Erred By Not Allowing Foreign Tax Credit Despite The Fact That Tax Was Paid Overseas & Form 67 Was Filed Before The End Of The Assessment Year.”

For Appellant: Shri Baldev Raj, AdvocateFor Respondent: Shri Kanv Bali, Sr. DR

Section 139(1)Section 143(1)Section 154Section 234ASection 250Section 90(2)

wrong in facts against natural justice. 2. That the learned Commissioner of Income Tax (Appeals) has erred by not allowing Foreign Tax Credit despite the fact that tax was paid overseas and Form 67 was filed before the end of the assessment year.” 2 3. Brief facts of the case ... declaring taxable of Rs.1,66,74,950/- and claiming refund of Rs. Nil. In this return, the assessee has claimed a foreign tax credit ["FTC"] of Rs.16,74,950/- by filing Form 67 u/s 90(2) of the Income- tax Act, 1961 (for short ‘the Act’), which was filed

Tessolve Semiconductor Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

ITA 310/BANG/2024[2021-22]Status: DisposedITAT Bangalore03 Jul 2024AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri. B. R. Sudheendra, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru

Section 139(1)Section 143(1)Section 250Section 90

Year 2021-22, assessee filed its original return of income on 10.03.2022. Thereafter, the assessee filed revised return on 28.03.2022 and claimed the Foreign Tax Credit (FTC) earned for the income earned by them outside India. The return was processed under section 143(1) of the Act and intimation ... natural justice- Section 143(1) 2.1. The learned CPC has erred in passing the intimation under section 143(1) by disallowing the foreign tax credit u/s 90 without issuing a communication as required under proviso to section 143(1) and without providing opportunity to submit the response by the appellant

Asha Rani Pandya, Indore vs. CPC Bangalore, Bangalore

In the result, the appeal is allowed

ITA 176/IND/2024[2019-20]Status: DisposedITAT Indore28 Jun 2024AY 2019-20

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniasha Rani Pandya Dcit/Acit-1(1) 389 1Ad- Scheme No.74C Indore Vijay Nagar, Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aqqpp7081A Assessee By Ms. Shreya Jain & Shri Prakash Jain, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 27.06.2024 Date Of Pronouncement 28 .06.2024

Section 139(1)Section 143(1)Section 90Section 91

disallowance of FTC in para 4.1 to 4.3 of the impugned order as under: “4.1 The Appellant is aggrieved by the denial of foreign tax credit of Rs.20,18,309/-, which according to CPC is not available when form 67 has not been filed before the time limit specified u/s.139 ... payers like that of the Appellant, it is brought on record that filing of Form no.67 is mandatory to claim the benefit of Foreign Tax Credit. 4.3 Taxes are paid in an alien nation, the particulars of which can never be verified by the Income tax Authorities

Incometax Officer, Chennai vs. Sandeep Kumar Singh, Chennai

In the result, appeals filed by the revenue for both the assessment years are dismissed

ITA 973/CHNY/2024[2020-21]Status: DisposedITAT Chennai28 Jun 2024AY 2020-21

Bench: Shri Manu Kumar Giri, Hon’Ble Judicial Membe & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 972 & 973/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20 & 2020-21 Sandeep Kumar Singh, Income Tax Officer, V. Flat No. 1-G, Door No. 148, Room No. 607, 6Th Floor, Annex Prithvi Apartments, Perambur Building, 121 M.G. Road, Barracks Road, Chennai – 600 034. Vepery, Chennai – 600 007. [Pan: Ashps-1760-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. N. Vijay Kumar, Ca ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई की तारीख/Date Of Hearing : 24.06.2024 घोषणा की तारीख/Date Of Pronouncement : 28.06.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. N. Vijay Kumar, CAFor Respondent: Shri. D. Hema Bhupal, JCIT

Section 154

matter of an order passed by the Assessing Officer u/s 154 of the Act on 02.02.2023 and 03.08.2022, denying Foreign Tax Credit of Rs.1,78,791/- and Rs.2,40,721/- for assessment years 2019-20 and 2020-21, respectively. Since the assessee :-2-: ITA. Nos: 972 & 973/Chny/2024 did not file ... provisions of the act and it would always be directory in nature. Respectfully following the same, we direct Ld. AO to grant impugned Foreign Tax Credit to the assessee. 4. In the result, appeals filed by the revenue for both the assessment years are dismissed. Order pronounced in the open

Incometax Officer, Chennai vs. Sandeep Kumar Singh, Chennai

In the result, appeals filed by the revenue for both the assessment years are dismissed

ITA 972/CHNY/2024[2019-20]Status: DisposedITAT Chennai28 Jun 2024AY 2019-20

For Appellant: Shri. N. Vijay Kumar, CAFor Respondent: Shri. D. Hema Bhupal, JCIT

Section 154

Mohammed Asim Naveed, Hyderabad vs. ITO Ward-5(3)(3), Karnataka

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 670/BANG/2024[2020-21]Status: DisposedITAT Bangalore27 Jun 2024AY 2020-21

Bench: Shri George George Kr Assessment Year : 2020-21 Shri. Mohammed Asim Naveed, Vs. Ito, Flat No.102, Mehdipatnam, Ward – 5(3)(3), Hyderabad – 500 028. Karnataka. Pan : Acxpn 7513 J Appellant Respondent Assessee By : Shri. Mohammed Afzal, Ca Revenue By : Shri. Ganesh R. Gale, Standing Counsel For Department. Date Of Hearing : 24.06.2024 Date Of Pronouncement : 27.06.2024

For Appellant: Shri. Mohammed Afzal, CAFor Respondent: Shri. Ganesh R. Gale, Standing Counsel for Department

Section 250

have heard the rival submissions and perused the material on record. On merits, the issue in question is with regard to Foreign Tax Credit (FTC). Prima facie the issue is covered in favour of the assessee by various orders of the Tribunal wherein it has been held that filing

Faisul Ramon Nagel, Mumbai vs. Income Tax Officer, International Tax Ward 3(3)(1), Mumbai

In the result, ITA No.1248/Mum/2024 is allowedfor statistical purpose

ITA 1248/MUM/2024[2020-21]Status: DisposedITAT Mumbai27 Jun 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

For Appellant: Shri Nimesh VoraFor Respondent: Shri Anil Sant, Addl. CIT DR

Section 139(1)Section 139(5)Section 143(1)Section 154oSection 244ASection 250Section 90

facts and in the circumstances of the case and in law, the learned CIT(A): 1. Erred in confirming non grant of foreign tax credit under Section 90/90A of INR 10,01,206. 2. Erred in not granting relief of foreign tax credit for the reason that requisite Form ... tax, the interest income amount of Rs. 14,959/-, income from foreign sources amount of Rs. 37,10,841/- and the correspondingly claimed foreign tax credit of Rs. 10,36,967/-U/s 90 of the Act. The ld. AO processed the revised ROI and passed an intimation under section

Manav Malik, Noida vs. ACIT Circle 5(2)(2), Gautam Budh Nagar

In the result, the appeal is allowed

ITA 2293/DEL/2023[2019-20]Status: DisposedITAT Delhi27 Jun 2024AY 2019-20

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2019-20 Manav Malik, Vs Acit, B-146, Sector-19, Circle 5(2)(2), Noida, Gautam Budh Nagar, Uttar Pradesh – 201 301. Uttar Pradesh. Pan: Apzpm1646L (Appellant) (Respondent) Assessee By : Ms Kirti Bindal, Ca Revenue By : Shri Subhra Jyoti Chakraborty, Cit-Dr Date Of Hearing : 29.04.2024 Date Of Pronouncement : 27.06.2024

For Appellant: Ms Kirti Bindal, CAFor Respondent: Shri Subhra Jyoti Chakraborty, CIT-DR

Section 139(1)Section 143(1)Section 154

filed the return on 30.08.2019 and the intimation in this regard was generated on 21.07.2021 wherein demand was raised by disallowing the foreign tax credit claimed by the assessee amounting to Rs.5,70,998/-. The ld. AR has submitted that the assessee had revised the return on 13th July ... 26th June, 2020. Thus, the short controversy is whether the CIT(A) was justified in sustaining the disallowance of assessee’s claim of foreign tax credit on the basis of delay in filing Form 67. The ld. AR has submitted that non-filing of the Form 67 is merely

Sumeet Subhash Narang, Mumbai vs. DCIT, Circle 42(3)(1), Mumbai

ITA 818/MUM/2024[2020-21]Status: DisposedITAT Mumbai26 Jun 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahay

Section 143(1)Section 250Section 90

APL/S/250/2023-24/1059350543(1) dated 04/01/2024 for assessment year 2020-21. 2. Following grounds of appeal have been raised: Ground No. 1: Non grant of Foreign Tax Credit ('FTC') of Rs. 15,33,519 On the facts and circumstances of the case and in law, the Ld. Additional/ Joint Commissioner of Income ... Ld.AO) of making the adjustment in the Intimation under Section 143(1) of the Income-tax Act, 1961 ('Act') of not allowing Foreign Tax Credit ('FTC') of Rs.15,33,519 allowable as per Section 90 of the Act read with Article 25 of the India-USA Double Taxation Avoidance Agreement

Monika Arya, Telangana vs. Income Tax Officer, Ward-5(3)(1), Bangalore

In the result, the appeal is allowed

ITA 913/BANG/2024[2017-18]Status: DisposedITAT Bangalore25 Jun 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

Section 139(1)Section 143(1)Section 250Section 90Section 90(2)

upholding the disallowance made by Centralized Processing Centre ('CPC') u/s 143(1) of the Income Tax Act 1961 (‘the Act’) in respect of foreign tax credit of INR 10,28,752 against the federal taxes paid by the appellant in the Canada on the doubly taxed Canada sourced income ... dated 11.6.2020 on the reason that assessee has not filed the Form No.67 along with return of income so as to claim the foreign tax credit. However, the same has been filed before the Ld. CIT(A) on 22.9.2018. The assessee has made the contention before Ld. CIT(A) that